AEA Needs Your Opinion on FAA's Proposed Safety Management Systems

SUMMARY: The FAA is soliciting public comments regarding a potential rulemaking requiring repair stations, air carriers and manufacturers to develop and implement safety management systems (SMS).

MAJOR HIGHLIGHTS: According to the FAA, a safety management system is a structured, risk-based approach to managing safety. The International Civil Aviation Organization (ICAO) has defined SMS as a “systematic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures.”

An SMS would provide a set of decision-making processes and procedures that AEA members would use to plan, organize, direct and control their normal, day-to-day business processes.

According to the agency, these FAA-“approved” decision-making processes would enhance safety and ensure compliance with regulatory standards.

AN SMS requires a proactive approach to discovering and correcting problems before there are safety consequences. An SMS also includes processes that seek to identify potential organizational breakdowns and necessary process improvements, allowing management to address a safety issue before a noncompliant or unsafe condition results.

Using an SMS, however, is not a substitute for compliance with FAA regulations or FAA oversight activities.

AEA COMMENTARY

The FAA makes it clear its proposed rulemaking is a significant administrative and operational burden, which will not substitute for compliance with FAA regulations or FAA oversight activities. Therefore, the FAA is proposing a significant additional burden without any financial, administration or administrative benefit to AEA members.

Clear, concise and focused answers to the FAA’s questions in its advanced notice of proposed rulemaking (ANPRM) must be generated to ensure this proposal is not simply an additional burden.

The AEA will be thoroughly reviewing and discussing this ANPRM during its AEA East and AEA Central regional meetings. This proposal is more burdensome than any of the early Part 145 proposals.

Comments are due Oct. 21, 2009. Please wait until after attending the AEA East or AEA Central regional meeting before commenting on this critical FAA initiative. The questions in the ANPRM can be misleading, which might cause you to unintentionally provide incorrect information that would support the FAA in mandating this new, overarching, regulatory “blanket” to your business.